MODERN SLAVERY ACT 2015 AND
TRANSPARENCY IN SUPPLY CHAINS ACT 2010
2021/22 BURBERRY GROUP PLC STATEMENT

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 andCalifornia Transparency in Supply Chains Act of 2010 (SB 657). It sets out the steps
we have taken during the financial year 2021/22 (the “Year”) to prevent slavery andhuman trafficking from taking place in our supply chains or in any part of our business.
Burberry’s definition of slavery and human trafficking is aligned to section 54 (12) of
the Modern Slavery Act 2015.
This statement is also made on behalf of the following subsidiaries of BurberryGroup plc (company number 3458224): Burberry Limited (company number 162636),
Burberry (UK) Limited (company number 4288292), Burberry International Holdings
Limited (company number 4251867), Burberry (España) Holdings Limited (company
number 5265289), Thomas Burberry Holdings Limited (company number 3509143),
Burberry Haymarket Limited (company number 4868493), Burberry Holdings Limited(company number 4251948) and Burberry London Limited (company number 4251951)
and the actions and operations set out below are effective across the Burberry group.

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INTRODUCTION
We are committed to being a force for good – through how we design, source, create
and advocate. Our Responsibility strategy has three focuses – climate, nature andpeople – underpinned by our determination to continually evolve and innovate ourapproach to safeguarding our planet for generations to come and enhance our metrics
to track, guide and report on progress.
To positively impact people within and beyond our value chain, we are drawing together
work across our business, from protecting and nurturing luxury craftmanship skills,
to driving progress towards our diversity, equity and inclusion targets, in order toestablish and evaluate the full picture of our impact on people within and beyond
our company. Respecting and upholding human rights, combatting the risk ofmodern slavery and increasing transparency throughout our supply chain are core to
this agenda.
This is our seventh Modern Slavery Statement and provides an overview of the
progress we’ve made over the past year in strengthening our systems to prevent
modern slavery in our supply chain and operations and how we have addressed
identified risks.
During this time, the COVID-19 pandemic remained a key source of concern and wehave focused on maintaining effective communication channels with our businessassociates to address the challenges of returning to work and maintaining a safe
environment for our people.
In FY 2021/22, we continued to adapt our Ethical Trading Programme and incompliance with updated COVID-19 restrictions resumed in-person engagement andmonitoring activities at our supply chain partners’ facilities where safe and legallyauthorised to do so. We also delved further into our raw materials supply chains to
identify new potential modern slavery risks.
We expanded and strengthened our training programme for both internal teams andsupply chain partners to spread awareness and build more effective prevention andmitigation actions.
Whilst our policies remained consistent throughout FY 2020/21 and FY 2021/22,
our global Ethical Trade team has remained vigilant to potential risks and the need to
update our policies accordingly.
We have continued to collaborate with cross-industry groups, such as the Business
Against Slavery Forum and the ILO Call to Action, to help target modern slavery.
We continue to monitor and assess our response to new emerging risk areas,
including those caused by the global pandemic.
As a responsible business, Burberry is closely monitoring the increasing trends
towards mandatory human rights and ethical trading due diligence legislation.
We continue to raise awareness and support our supply chain partners’ compliancewith such standards.

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OUR BUSINESS AND SUPPLY CHAIN
Burberry is a global luxury brand, headquartered in London, UK. We design, source,
make and sell luxury products under the Burberry brand and our business model isfocused on creating long-term sustainable value for all our stakeholders. Creativity
has fuelled Burberry throughout our brand’s 165-year history and our sharedconviction in its power is central to how we operate as a company.

\•

Over 9,000 employees•

115 nationalities•

Across 33 countries•

415 stores•Over 30 Responsibility Specialists•

FY2021/22 revenues: 2.8 billion £Our Purpose: At Burberry, we are guided by the core belief that Creativity
Opens Spaces. Reflective of how we operate as a company, our purpose
informs the choices we make and shapes our long-term goals.
Our Values: Our purpose is underpinned by our values. Being creatively
driven, forward thinking, open and caring, and proud of our heritage arehallmarks of our organisation at its best and have remained core to ourbrand since the Company was founded in 1856.

Design: We harness creativity to design beautiful luxury goods that are made to last.
Our teams collaborate from the earliest stages of product development so that ourdesign, strategy, marketing and responsibility functions are aligned and working with
common goals in mind. Sustainability and doing the right thing for the environment
are always a priority.
Source: To create beautiful sustainable luxury goods, we source the finest materials
available from our global network of suppliers. We think and act creatively in order
to inspire and delight our customers while ensuring sustainability and environmental
considerations are prioritised.
Make: We make our products at Burberry-owned sites in the UK and Italy, as well as
through a network of global suppliers. We strive to deliver products of the highest
quality to our customers and invest in driving improvements throughout our supply
chain. We are aware of the impact of our production processes on the environment andactively reduce, reuse and recycle the waste we create while investing in innovative
solutions to help us move towards a circular business model.
Sell: We sell Burberry products through our directly operated and franchised stores,
as well as via wholesale partners and online. We use the product and distribution
expertise of licensing partners for certain product categories, such as eyewear andbeauty. To inspire and excite our customers and prospective customers, our creative,
marketing and communications teams create distinctive and meaningful content aswell as luxury experiences that speak to our brand heritage and purpose.
Contributing to local economies and partner value: Operating across the world,
we contribute to local economies and support the communities around us. We add
value to societies both directly and indirectly through our business operations andby partnering with NGOs on community programmes.

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SUPPLY CHAIN
We rely on a global network of raw material and finished good suppliers that support
the production of our products and our general day-to-day business operations.
Our supply chain partners are accurately screened and assessed at onboarding to
identify any human rights and modern slavery risk. Additionally all suppliers are
required to acknowledge and sign Burberry’s Responsible Business Principles during
onboarding to ensure mutual agreement that any form of modern slavery, included
forced, bonded or involuntary prison labour, is not permitted whatsoever.
As part of our commitment to uphold human rights within our supply chain, we also
continually assess human rights risks and labour conditions across our global supply
chain through our Ethical Trading Programme, established in 2004. Since 2019 wehave continued to expand our responsibility programme to also include the assessmentof mills, tanneries and trim suppliers and their sub-contractors. In FY2021/22 thisincludes the suppliers of raw materials for approximately 45% of our products.
Further details on our supply chain due diligence process are provided in the section
below “Due diligence and assessment of our supply chain”.
APPAREL AND ACCESSORIES
Finished products are manufactured at both company-owned facilities in the UK and
Italy and by an external supplier network. A large part of our finished goods production
takes place in Europe, where Burberry has many long-standing relationships, several
extending beyond 15 years. Over 85% of the finished goods facilities we source fromare covered by National and/or Industrial Collective Bargaining Agreements andmany have established union representation enabling workers to remain informed
and involved in discussions about their rights. We believe that these strong supplier
relationships are key to ensuring continuous improvement in supply chain working
conditions and help us to minimise supplier turnover, where possible. We have visibilityof all finished goods manufacturing suppliers, their subcontractors and supporting
facilities, as well as mills, tanneries and trim suppliers that supply our finishedgoods partners.
RAW MATERIALSWe are conscious that our raw materials supply chains are at risk of modern slavery
and human rights violations. For this reason, we’ve introduced new targets in our raw
material supply chains to strengthen our supply chain visibility. These include:•

Ensure all key materials are 100% traceable by 2025. The key raw materials we
use are cashmere, cotton, wool, polyester, nylon and leather. For these materials
we will achieve traceability to a minimum of country level. This target achievement
will be supported by our use of certified materials where the country of origin isverified and disclosed.

•

Source 100% certified recycled nylon and recycled polyester by 2025, where nylon
or polyester is the product’s main material.

•

Source 100% certified wool by 2025, supporting certifications that uphold thehighest animal welfare standards.

•

Source 100% certified organic cotton by 20251.

•

Source 100% of our leather from certified tanneries by 2025 with environmental,
traceability and social compliance certificates2.

This builds on our target to source 100% of our cotton more sustainably by 2022
This builds on our target to source 100% of our leather from certified tanneries by 2022

1

2

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LICENSEES
Production of our beauty and eyewear products is licensed to Coty and Luxottica
respectively. Our Responsibility team works with both licensees to ensure they apply
consistent standards which align with those adhered to across the rest of Burberry’s
supply chain. Further information can be found on Coty and Luxottica’s Modern
Slavery Statement.

BUSINESS OPERATIONS
As a large global organisation, we work with a number of suppliers that support ourbroader business operations across EMEIA, Americas and Asia Pacific including,but not limited to, retail stores, our e-commerce and business websites, offices,marketing and transport. We continue to communicate our commitments and policies
designed to prevent forced, bonded and trafficked labour through our Responsible
Business Principles (the “Principles”) to these suppliers. Further details are set out
in the following sections.
In addition, we included our distribution centres, packaging, visual merchandising,
repurposing and recycling supply chains within our Ethical Trading Programme as of
FY2018/2019. We conduct a risk-based analysis of new suppliers prior to procurement
and run Ethical Trading audits where any risk is identified.

COVID-19
Through the COVID-19 pandemic our Responsibility team remained in close contact
with supply chain partners. Last year we organised regular calls and desktop
assessments to identify supply chain needs, while this year, we have largely resumed
onsite visits and audits, maintaining a blended physical and virtual ethical trade
auditing approach.
Building on our COVID-19 safety and containment measures, in FY 2021/22, we
focused on providing our key vendors with mental health coaching sessions to support
team members throughout the pandemic. Led by an external, specialist consultancy,
the training provided our key vendors’ Corporate Responsibility teams with knowledge
and tools to manage their emotional wellbeing and that of the people in their supply
chains. The training covered topics such as how to control emotions under stress, how
to build empathy, how to motivate themselves and others in challenging environments.
We are also making full use of our confidential worker hotlines to ensure that we
remain responsive to workers’ needs.
In addition, an Infection Control Management Policy was communicated to all vendors
and key raw material suppliers in 2020 to support them in providing a safe working
environment and we continued to closely monitor its implementation at supply chain
partners’ sites.
In June 2020, we became signatories of the COVID-19: Action in the Global Garment
Industry call to action, set out by the International Labour Organisation (ILO) andendorsed by organisations such as the Fair Labour Association and International Trade
Union Confederation. The initiative is working towards bringing the industry together
in regards to implementing more efficient social security systems as a collaborative
group. As well as working in collaboration with these stakeholders, we have continued
to work with NGOs, suppliers, vendors and strategic partners across our sourcing
regions to continue the development of our Ethical Trading Programme to ensure
workers’ rights are maintained during the course of the global pandemic.

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7

POLICIES
We believe that respect for human rights is integral to being a responsible company.
The prevention of forced, bonded and trafficked labour is a key element of Burberry’s
Human Rights Policy and Ethical Trading Code of Conduct.
BURBERRY POLICIESTo promote human rights across our direct and indirect business operations, we
require our network of business associates and extended supply chain to comply with
our Responsible Business Principles contained within Burberry’s Code of Conduct.
The Principles have been developed in line with our commitments and experience
over a number of years. They have been informed by our longstanding membershipof the United Nations’ Global Compact, and are underpinned by the ETI BaseCode, International Bill of Human Rights and the Fundamental Conventions of theInternational Labour Organisation. We review and update the Principles on an annual
basis to ensure that they align to the latest good practice guidelines and any emerging
regulatory requirements. The Principles apply to all our business associates, which
include, but are not limited to: finished goods vendors, subcontractors, supporting
facilities, raw material suppliers, non-stock suppliers, construction contractors,
licensees and franchisees.
Since 2016, the Principles have expressly addressed modern slavery risks.
Incorporation of the Principles into our contracts with business associates ensures
the provisions targeting modern slavery are also included. The Principles are overseen
by Burberry’s Ethics Committee, chaired by our General Counsel, and are monitoredby our Responsibility and Supply Chain teams. They are enforced pursuant to theBurberry Non-Compliance Policy, detailed below.
The Principles include Burberry Code of Ethical Business Principles, Anti-Bribery
and Anti-Corruption Policy and Global Environmental Policy, and the following
seven policies:
ETHICAL TRADING CODE OF CONDUCTThis outlines requirements which all our business associates must uphold in relation
to their own employees, contracted labour and throughout their own supply chain.
The code includes, amongst other standards, the following requirements:that employment is freely chosen, child labour is not used, freedom of associationis respected and no harsh or inhumane treatment occurs.
The full Ethical Trading Code of Conduct is available here: Burberry Ethical Trading
Code of Conduct.
MIGRANT WORKER POLICYThis is specifically intended to protect workers who may be vulnerable to exploitationin the course of international migration. The policy contains requirements including,but not limited to, the prohibition of withholding passports and similar documents andthe levying of recruitment fees. During FY 2020/21, we updated this policy based onlearnings from partnering with Issara Institute, an NGO specialised on recruitment
journeys for migrant workers in supply chains. We then recommunicated this policy tobusiness associates to provide more detailed guidance on implementation of the policy
and meeting the standards within it.
The full Migrant Worker Policy is available here: Burberry Migrant Worker Policy.

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HUMAN RIGHTS POLICY
Burberry’s Human Rights Policy sets out four key stakeholder groups – our people,
workers in our supply chain, our customers and our communities - and the procedures
we have put in place to protect and uphold human rights, including mechanisms inplace to address any instances of potential infringement. The policy was developedwith reference to the United Nations’ Guiding Principles on Business and Human
Rights. We assess human rights impacts and monitor labour conditions in both ourown operations and our supply chain on a regular basis to ensure the policy is upheld.
The policy was updated during FY 2020/21.
Further details of Burberry’s Human Rights Policy are available here:
Burberry Human Rights Policy.
CHILD LABOUR AND YOUNG WORKER POLICY
We prohibit all forms of child labour in our own operations and throughout our supply
chain. In our Ethical Trading Code of Conduct, we state that we will never use childlabour and outline provisions for young workers.
Our Child Labour and Young Worker Policy expands on the Ethical Trading Codeof Conduct and includes standards relating to implementation, monitoring andremediation procedures which must be followed by all business associates.
This policy was updated in FY 2020/21.
Further details of the Child Labour and Young Worker Policy are available here:
Burberry Child Labour and Young Worker Policy.
RESPONSIBLE SOURCING POLICYThis outlines Burberry’s commitment to responsible and sustainable businessprinciples throughout the supply chain. The policy outlines specific prohibited sourcing
regions, where the risk of modern slavery and other labour rights issues is recognised.
For example, the policy prohibits sourcing from certain countries including but notlimited to Bangladesh, Pakistan and Cambodia.
The policy was last reviewed in FY 2020/21.
Further details of the Responsible Sourcing Policy are available here:
Burberry Responsible Sourcing Policy.
PARTNER NON-COMPLIANCE POLICY
Where breaches of our standards and policies are identified, Burberry collaborates
with local partners to find solutions to address non-compliance. Where improvements
are not made within a given time or there is an unwillingness to address the issue,
we may consider terminating a particular business relationship. The policy is designed
to allow partners a reasonable amount of time to rectify non-compliances with the
Principles, to minimise any potential detrimental impact on workers’ livelihoods,
while always reserving the right to terminate contracts and take any other legal action
possible, depending on the nature of the breach.
Further details of the Partner Non-Compliance Policy are available here:
Burberry Partner Non-Compliance Policy.

9INFECTION MANAGEMENT CONTROL POLICY
To support our business associates in ensuring a safe and healthy environment
for employees, customers, partners and visitors during the COVID-19 pandemic,
this policy sets out the minimum standards which Burberry requires its businessassociates to comply with.
The policy covers infection controls such as social distancing, Personal Protection
Equipment (PPE) requirements and cleaning programmes that must be observed onsite. In addition, Burberry recognises, within its supply chain, that there are manydifferent countries each with their own laws and therefore all business associates
must ensure that, in addition to compliance with this policy, it continues to comply
with local regulations, laws and industry best practices.
In addition to the Principles, Burberry provides a range of resources and guidelines
for employees to follow, which relate to a wide range of matters including personal
conduct and whistleblowing. Burberry employees, contractors and agency workers
across our operations also have access to a confidential whistleblowing hotline which
ensures that there is always a way to report issues if usual routes of escalation areunavailable or restricted.
We continue to implement additional risk management of our global non-stock
procurement supply chain to gain more visibility of areas of greater risk, such as labour
suppliers and construction contractors. Suppliers are required to take responsibility
for the prevention of forced, bonded and trafficked labour in their supply chain andcertify that neither they nor any of their affiliates, contractors or sub-contractors
engage or have engaged in any form of modern slavery.
Compliance with the Principles is a requirement of doing business with Burberry.
Adherence to the Principles is included in contracts with suppliers. They sign a
letter of undertaking confirming, amongst other matters, their commitment to the
Principles and responsibility to cascade the Principles within their own supply chains.
We work with our business associates to support their compliance and we reserve theright to cease our sourcing relationship with those that do not demonstrate sufficientcommitment to the Principles or are in significant breach of them. In the event of abusiness associate being found to be involved in modern slavery, we would act firstto help safeguard the affected workers’ wellbeing and then to support the businessassociate with its remediation process, including any actions to identify and address
root cause issues.

10GOVERNANCE
We continue to promote the management of modern slavery risks within Burberryand externally.
We have a global Responsibility team consisting of over 30 specialists in key locations
globally. Although ethical trading activities are coordinated by our Responsibility
team, targets relating to working conditions in the supply chain are owned by our
Supply Chain and Sourcing teams. Burberry employees who are responsible for supply
chain partner relationships and sourcing also have personal KPIs related to labour
conditions, recognising the potential impact of fair purchasing practices on labour
conditions throughout our supply chain.
Our Ethical Trading Programme is supported and monitored internally by a numberof management committees. The programme aims to ensure that the potential
risks to labour and human rights are considered at all appropriate levels and areasof the business. Policies relating to human rights are reviewed and approved by thecompany’s Ethics Committee. In the event that any labour or human rights risks are
identified, the Vice President of Corporate Responsibility will report on such issues
to the Ethics Committee as well as the Group’s Risk Committee, which meets atleast three times a year. The Risk Committee is chaired by the Chief Operating and
Financial Officer, who sits on the Burberry Group plc Board. The Risk Committee
reports into the Group’s Audit Committee which is chaired by an independent
non-executive director.
Additionally, our social responsibility and sustainability strategies are reviewed by
the Sustainability Committee co-chaired by the CEO and CFO/COO. The CEO is alsoa member of the steering committee of the Fashion Pact, while the CFO/COO is alsoa member of the Leadership Network for the Accounting for Sustainability initiative(A4S), the Sustainable Market Initiative and N.10 Business Council. Objectives andprogress on social responsibility and human rights topics are reviewed by our Impact
Forum, comprising independent external experts who play the role of “critical friends”.
The governance structure chart below outlines the reporting lines of each of
the committees.
BURBERRY GROUP PLC BOARDCEOSUSTAINABILITYCOMMITTEENOMINATIONCOMMITTEE

AUDIT COMMITTEERISK COMMITTEEREMUNERATIONCOMMITTEEETHICS COMMITTEE

TCFD WORKING GROUP

In October 2017, Burberry became a founding member of the Business Against Slavery
Forum alongside some of the UK’s largest companies. Since then, our Responsibility
team has been participating in the forum’s quarterly meeting and ad hoc workshops.
The forum is convened by the UK Home Office and member companies share
intelligence and best practice as well as inform the Government action to help
businesses identify, tackle and prevent slavery in their supply chains.

11DUE DILIGENCE AND ASSESSMENT OF OUR SUPPLY CHAIN
Since 2004, we have implemented a programme to monitor the labour conditions in
our product supply chains and safeguard the workers engaged in them.
Monitoring and verification activities are completed throughout our finished goods andkey raw material supply chains to support compliance with the Principles. To ensure
our supply chain mapping stays up to date, we operate a strict approval process andconduct a transparency analysis with our vendors and commercial teams at regularintervals. Following this analysis, we conduct an assessment to identify any new or
emerging areas of risk.
New raw material suppliers are required to confirm they will adhere to the Principles
and comply with applicable local laws. Right from the onboarding stage, they arealso required to agree that we may visit and assess their own compliance and that of
their suppliers at any time. Before any new supplier is approved to participate in the
Burberry supply chain, they are risk assessed for social compliance and any indicationof forced, bonded or trafficked labour. If during this risk assessment a vulnerable
workforce or geographical location risk is identified, a full audit will be completed andthe results and the remediation plans (if any) will be evaluated before a decision onwhether or not to approve is taken.
New raw materials suppliers onboarding process:

New Raw Material
Supplier onboarding
request submitted

Raw Material Supplierto fill in onboarding
documentation and sign
Burberry Responsible
Business Principles

Raw Material Supplierrisk assessment
conducted by Burberry
Responsibility Team

Raw Material Supplierapproved only if nosevere non-conformity
is identified

In case of modern
slavery or other social
compliance risk being
identified, audit
conducted

In addition, before a factory is approved to produce Burberry finished goods, we assess
its compliance with the Principles and applicable local laws and commitment to upholdthem. The Responsibility team must be satisfied that the factory will uphold thesestandards before giving approval for production to begin. Such assessment includes
an Ethical Trading Audit. Audits are conducted by qualified internal auditors, and aresupported by interpreters and cultural facilitators where required. External accredited
auditing agencies are appointed to conduct audits only in a limited number of cases.
Audits, announced or unannounced, consist of worker interviews, document reviews
and site tours, including workers dormitories and communal facilities, and are
repeated periodically to confirm ongoing compliance and continuous improvement.
The frequency of audits depends on the level of performance in previous audits– better performing factories are audited less frequently. Facilities where more
severe non-conformities are identified are audited every three to six months and,between audits, our Responsibility team works closely with them to support theimplementation of required improvements. Worker interviews are always conductedconfidentially and workers are selected at random with fair representation of theworkforce including, for example, union and worker representatives, first aiders,migrant workers and a gender diverse sample. Our audit methodology prescribesthat we interview at least 10% of the workers in a factory.

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In normal circumstances, interviews take place within the factory premises, but offsite
interviews might be conducted if necessary to validate the findings while protecting
workers. Between audits, our Responsibility team works closely with facilities toimplement systems to prevent modern slavery and improve the management of humanrights and health and safety risks. During the FY 2021/22, we conducted 601 audits
and 28 engagement activities.
Our audits also address the risk posed by unauthorised subcontracting. As a globalorganisation, we accept our responsibility to support and guide our partners by raisingawareness of associated risks of modern slavery at subcontractors. Our partners
have extended the no-tolerance policy of unauthorised subcontracting to all of
their partnerships and in some cases implemented digital tracking systems toprevent outsourcing.
New finished goods suppliers onboarding process:New finished good
supplier onboarding
request submitted

Finished Good Supplierto fill in onboarding
documentation and sign
Burberry Responsible
Business Principles

New finished goods
supplier risk assessment
conducted by Burberry
Responsibility Team

Supplier approved only if
no severe non-conformity
is identified

Audit conducted

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ASSESSING OUR HUMAN RIGHTS IMPACT
Every two years, we conduct a Human Rights Impact Assessment (HRIA) of ouroperations and activities and those of our extended supply chain. If a forced labour risk
is identified, ethical trading assessments are conducted by our internal teams or bya local NGO, where local expertise is needed, to identify any labour rights issues andremediation required.
We have implemented this process since 2014 and continue to evolve and develop ourhuman rights diligence approach as well as our Ethical Trading Programme. As partof this, over the last two years we have implemented a number of mitigation actionplans focused on migrant workers and women in our supply chain as we identified thatthese groups are disproportionately more vulnerable to modern slavery risks. Actionplans included context specific interventions such as mapping recruitment journeys in
identified hotspots, building worker voice mechanisms in these areas and working withexperts to integrate gender sensitive processes and metrics into our programmes.
We have expanded our Ethical Trading Programme to cover all distribution andfulfilment centres globally, including the evaluation of recruitment practices acrossthese sites.
In FY 2020/21, our Human Rights Impact Assessment highlighted three areas as
those where human rights violations are more likely to be identified across our finishedgoods and raw materials suppliers. These are:•Diversity, Equity and Inclusion•

Worker voice•

Modern Slavery

We have implemented actions addressing all three areas. On diversity, equity andinclusion, we have strengthened our partnership with cultural mediators and provided
migrant workers with tools to expand their awareness about public services andfacilitate access to them. In relation to worker voice, we have continued to sponsor
our hotlines, which remain a key tool to capture workers’ needs. Over the last year,
we have also expanded the hotlines reach to new countries. As our supply chain evolves,
we’ll continue to monitor that our hotline reach remains relevant and workers in thegeographies we operate in are provided with adequate tools to make their voice heard,
raise any concerns and seek support. Finally, in response to modern slavery risks,
we monitor that our policies remain relevant, we strictly implement our due diligenceprocess at onboarding and we keep refining our audit tools. We also conduct training
for both internal teams and supply chain partners to raise awareness and provide tools
to prevent and mitigate this risk.
In addition, our FY 2020-21 HRIA highlighted increased risk for workers in relation
to the COVID-19 pandemic, particularly in relation to workers’ health and wellbeing.
In response to this, the Burberry Responsibility team has supported supply chain
partners through the challenges presented by the pandemic by communicating
Burberry’s Infection Control Management Policy, training on safe work environments
and mental health, conducting onsite visits as well as remote engagement activities toassess risks and provide guidance.
In FY 2021/22, we also continued to explore and assess risks associated with raw
material commodities at their source. We have been working with our raw material
suppliers to further map and assess potential risk areas. As part of the assessment
we engaged with our supply chain partners to better understand the dynamics of theirsourcing and supply chains.
We introduced new raw material and traceability targets in FY 2021/22 to support
and complement human rights risk mitigation throughout our supply chain throughcertification and we are currently on track to achieve these ambitious 2025 targets.

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STAKEHOLDERS ENGAGEMENT AND WORKERS VOICE
During Ethical Trading audits and as part of our broader responsibility programme,
we conduct interviews with relevant stakeholder groups and workers to better
understand their needs and perceptions, while gathering insights into the direct
and indirect impacts of our business and developing focused mitigation plans
where required.
We also provide grievance mechanisms for our global employees, as well as
confidential hotlines run by NGOs for workers in our supply chain which aim to address
workers’ complaints, providing consulting services and psychological support.
During FY 2021/22, Burberry-sponsored hotlines received 435 calls, covering 36
factories and over 19,000 workers. Calls and their resolution have been monitored
closely by our Responsibility team.
Monitoring alone does not drive improvements in labour conditions and therefore
we have several other programmes in place to support our supply chain partners to
improve labour conditions.
WORKER GRIEVANCE MECHANISMS
Labour rights issues can include inadequate access to remedy. Where this occurs,
we work with local NGOs to establish a hotline to share information with workers
on their labour rights, create a mechanism to report grievances and provide
psychological support.
The effectiveness of the hotline is frequently reviewed by our Responsibility teamand this year we extended the hotline to cover over 19,000 workers within our supply
chain. During FY 2021/21, 435 calls (15 complaints, 409 consulting requests and11 psychological support requests) were received. Resolutions were monitored closely
by our local Responsibility teams.
We continue to review access to remedy and we will extend the hotline where required,prioritising suppliers with migrant workers.
WORKER WELLBEING
We continue to work on programmes to capture comments and grievances fromworkers in our supply chain globally and address issues raised.
Based on previous years’ experience and supply chain feedback, we have enhanced
the tool developed with Oxfam to measure worker wellbeing in our supply chain andcapture comments and feedback from workers. In FY 2021/22 we reached over 3,300
workers across 30 facilities globally.
The results have been used to develop specific action plans for each factory.
Different needs have emerged according to the factories’ geographies and theimprovement actions span from the development of stronger HR management
systems, to worker and supervisor training programmes to initiatives to promoteinternal dialogue. For instance, some finished goods facilities have implemented
clearer hiring policies and procedures while others have set up new Wellbeing
Committees where Management and Workers’ representatives can discuss emerging
needs and identify joint solutions on a regular basis.
In the coming year, we will work to further expand the number of workers involvedin the programme, whilst also supporting the factories with the successful
implementation of their action plans. The positive impact of the implemented actions
will be monitored by running our wellbeing measurement tool across selected facilities.

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CHAMPIONING DIVERSITY AND ENSURING INCLUSIVITYAt Burberry, our global Diversity and Inclusion strategy is focused on valuing andembracing differences and creating an environment where everyone feels they belong,
has a voice and can reach their full potential. We know that when this happens,
our colleagues are more engaged, committed and effective in driving results andwe make a more meaningful contribution to the world around us.
To help achieve our diversity and inclusion goals, our dedicated Global Diversity
and Inclusion team works with colleagues across the business, including our seniorleadership teams, the broader Human Resources team and our advisory networks,
with a focus on four strategic pillars:•

attracting and retaining diverse top talent•

fostering an open and inclusive culture•

educating and raising awareness•

implementing a global approachD&I is also a key focus for our supply chain. Last year we reviewed and updated our
Migrant Worker Policy to strengthen our guidance on the repayment of recruitment
fees and better support our partners in implementing and upholding an ethicalrecruitment journey within the supply chain and we keep monitoring the policy
implementation.
We have mapped particular risk areas and are working closely with local expert
organisations and our suppliers to develop roadmaps to mitigate risk to domestic andinternational migrant workers in key supply chain locations.
In FY 2019/20, we introduced an inclusivity programme in Italy with a third-party
communication agency and a cultural mediators association to increase vulnerable
workers’ access to local institutions and public services. The overall aim of the
programme was to empower workers, thereby reducing risk of modern slavery and in
the long-term, having a positive impact on social inclusion. This programme, together
with our onsite audits, has helped us to identify the need to provide migrant workers
with a dedicated tool to ask for guidance and support. In the next financial year we will
be focusing our efforts on evolving our approach to respond to this opportunity andbetter support migrant workers in our supply chain.
We will continue to strengthen our commitment by continuously reviewing ourprogrammes and taking action where needed.

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TRAINING AND RESOURCES
Our Responsibility team includes specialists in labour and human rights and modern
slavery. Burberry employees are introduced to Burberry’s responsibility policies andprogrammes during their induction training to ensure a general understanding of
Burberry’s responsibilities in this area.

BURBERRY INTERNAL TEAMS TRAININGIn FY 2016/17, we developed our first bespoke modern slavery and labour rights
training programme for our internal teams and supply chain partners, informed by
Burberry’s Human Rights Impact Assessment and in collaboration with the ethicaltrade, human rights and labour standards consultancy Impact. In FY 2021/22, over 120
members of our internal supply chain, sourcing, internal manufacturing and productteams received either introductory or refresher training. The targeted training helps
those who have close contact with our extended supply chain to be familiar with therisk areas, likely indications of human rights abuses (including instances of modern
slavery) and possible actions to take if an incident of modern slavery is identified.
In previous years, we also trained members of our human resources, health andsafety, construction and fulfilment teams on modern slavery, how to identify it andappropriate actions to take. A refresher training will be organised again next year.
This training has helped embed respect for human rights and a policy of zero tolerance
for modern slavery throughout the business.
We regularly review training needs across our business operations to ensure all
relevant employees are included. In FY2022/23 we will create new online resources
and continue to conduct trainings to reach a wider audience of employees and further
embed awareness and risk mitigation into our culture.

SUPPLY CHAIN TRAINING
Since FY 2016/2017, we have been training our supply chain partners, including
vendors and key raw material suppliers, on understanding, identifying and managing
modern slavery risks. In FY 2018/19, our UK Responsibility team completed an“Investigative Interviewing Skills” course developed and delivered by the Gangmasters
Labour Abuse Authority and Stronger Together. The skills learned have been used to
improve our Ethical Trading Audit methodology and have helped to provide insightwhen working with our regional teams. In addition, since the end of 2019 theBurberry EMEIA Responsibility team has collaborated with partners with cultural
integration expertise to further strengthen our due diligence activities in
multi-cultural environments.
In line with the commitment we made in FY 2020/21, this year’s training has reachedour key global product supply vendors and raw material suppliers covering 80% of
our production. They have attended a three hour training session on modern slavery
identification and management within their own operations and extended supply chain.
All training participants have been tasked with the development of action plans toembed modern slavery awareness and prevention within their companies.
As part of our broader supply chain training programme, we also delivered a “Train theTrainer” course to 17 key finished goods vendors in Italy, one of our primary sourcing
countries, to support them in cascading the modern slavery training within theircompany and to their own supply chain partners.

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As part of the training objectives, we stressed that any instance of modern slavery is
not tolerated and will be addressed in line with our partner non-compliance policy. If asuspected case of modern slavery emerges, supply chain partners have been trained
to act in the first instance to ensure the safety of the persons at risk and Burberry will
support them in identifying the most appropriate course of action.
During FY 2022/23 we will continue to monitor the implementation of our suppliers
action plans. Moreover, we will continue to deliver annual modern slavery training toour key finished goods vendors and raw material suppliers to ensure that our main
suppliers are well equipped to understand and address this topic and their attention
remains high.

KEY PERFORMANCE INDICATORS (KPIs)
We monitor the KPIs set out below on an ongoing basis. These KPIs help us ensure
the effectiveness of our efforts to address modern slavery risks and are continuallyreviewed.
BURBERRY INTERNAL TEAMS TRAINING
The Burberry Responsibility team trains key internal teams working with our businessand product supply chains. This includes sourcing, supply chain and logistics, productdevelopment, HR, legal, construction, procurement and workplace services.
In FY 2021/22, the supply chain, sourcing and product teams received either introductoryor refresher training to better understand forced labour indicators and raise awarenessof modern slavery risks within our business operations and supply chain.
SUPPLY CHAIN TRAINING
We regularly train finished goods suppliers, their key subcontractors and key raw
material suppliers on the identification of modern slavery and building systems toprevent the occurrence of modern slavery.
WORKER VOICE
We continue to implement initiatives to strengthen workers’ access to informationand the ability to raise grievances as well as to measure worker wellbeing. During
FY 2021/22, Burberry’s worker hotline received 435 calls, categorised as 15 complaints,
409 consulting requests and 11 psychological support requests.
We also surveyed approximately 3,300 workers across 30 facilities globally tobuild a better understanding of workers’ wellbeing and identify opportunities for
improvement. In FY2020/21 we introduced a communication training programmein two European production facilities and further expanded it in FY 2021/22 to two
additional suppliers where a need was identified. The aim of the programme was tobuild communication skills and improve interaction between workers, supervisors
and factory management. As a result, the facilities introduced stronger worker
consultation and feedback mechanisms, improving internal dialogue. We continued
to evolve our approach to workers’ wellbeing to better capture and measure key
wellbeing dimensions and more effectively address worker priorities. Our key vendors
were consulted to inform the review of the methodology and ensure their input andsuggestions were taken into account.
In FY 2022/23, we’ll further expand the tool reach and monitor the results of our updated
wellbeing model as well as continue gathering feedback from our supply chain partners.
This will allow us to identify any further opportunity for improvement or any needs fortargeted action.

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AUDITS AND ASSESSMENTSIn FY 2021/22, we conducted 601 ethical trading audits and 28 engagement activities.
The majority of these activities were conducted by our internal Responsibility team
who endeavour to build trust in our ongoing partnerships and drive continuous
improvement.
Since the start of the global pandemic in March 2020, the Responsibility team has
remained in close contact with supply chain partners by developing a blended physicaland virtual ethical trade auditing system. Over FY 2021/22, we have maintained thisapproach to continue protecting the health and safety of our own as well as supply
chain partners employees. However, when and where the circumstances have allowed,
we have given preference to onsite monitoring activities as these allow to better
capture any challenge and provide more effective support.
The audit and assessment programme covers all our finished goods facilities and theirsubcontractor supply chains as well as raw material suppliers covering over 40% of
our finished products.
In early 2020, in an area of our supply chain where we identified a group of migrant
workers paying fees during a complex recruitment journey, we started working witha local NGO, Issara Institute, and two suppliers who operate four facilities to build
worker voice and remediate any fees paid by existing workers as well as workers that
had since left their employment.
With remediation work now completed, in FY 2022/23 we will continue to focus on
implementing measures for an ethical recruitment route for migrant workers andcontinue collaborating with our supply chain partners to support them in abiding by
the designed guidelines. Facilities where domestic and international migrant workers
are employed remain a key focus area.

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LOOKING AHEAD
We continue to strengthen the breadth and depth of our human rights due diligenceand Ethical Trading Programme as well as implement the action plans resulting from
our FY 2020/21 Human Rights Impact Assessment. A key focus has been on our
upstream raw materials supply chain and engaging with key certification bodies toensure human rights due diligence is conducted and embedded within certification
standards.
Over the next year we’ll increase our efforts to strengthen our supply chain
traceability, in line with our 2025 commitments. We believe that our focus ontransparency and traceability throughout the supply chain will further strengthen
our ability to identify modern slavery risks and address any new challenge that might
emerge.
In addition, we will continue to support our supply chain partners through challenges
presented by the COVID-19 pandemic and monitor potential emerging risks andimpacts in our extended supply chain.
Finally, our commitment to become Climate Positive by 2040 will allow us to not
only protect the environment but also the communities that live within it. We aim
at building a model that allows both the environment and people to thrive, reducing
human rights violations and modern slavery risks.
We continue to review our own business operations and procurement procedures toensure that risks of modern slavery are considered.
Should any instances of modern slavery be identified, we believe we are well positioned
to address these and to support any affected workers in line with our core values.
Approved by the Board on 12th May 2022 and signed on its behalf by:
Jonathan Akeroyd
Chief Executive Officer
Burberry Group plc

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